36In that regard, it should first be noted that, whilst the third paragraph of Article 50 EC refers only to the active provision of services, where the provider moves to the beneficiary of the services, well-established case-law shows that the freedom to provide services includes the freedom of the persons for whom the services are intended to go to another Member State, where the provider is, in order to enjoy the services there (Joined Cases 286/82 and 26/83 Luisi and Carbone [1984] ECR 377, paragraphs 10 and 16). In the main proceedings here, the issues are the refusal to grant tax relief on the ground that the private school attended is established in another Member State and, hence, the possibility of taking advantage of offers of education emanating from such a school.
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